State v. Boyd, 204 Conn.App. 446

In 2006 Boyd pleaded guilty under the Alford doctrine to first‑degree assault (plus a risk‑of‑injury count) as part of a global plea resolving multiple files; the plea included a fixed 20‑year term (five years mandatory) and the state nolled other charges.
At the plea hearing the court and prosecutor stated no taped statement by witness Thomas Lopes existed; sentencing followed the agreed‑upon 20‑year term.
After sentencing Boyd obtained a transcript of a Lopes taped statement that arguably reduced Boyd’s culpability (suggesting reckless rather than intentional conduct).
In 2017 Boyd filed a motion to correct an illegal sentence, asserting the sentencing judge relied on inaccurate information (the court’s belief that no Lopes tape existed) and thus his right to be sentenced on accurate information was violated.
The trial court concluded the claim, while facially invoking sentencing‑manner jurisdiction, in substance attacked the plea and denied the motion; the court did not find that the sentencing judge had relied on the alleged inaccurate information.
The Appellate Court held the claim was actually a collateral attack on the plea (outside the narrow post‑sentencing jurisdiction to correct illegal sentences) and remanded to have that portion of the motion dismissed (while affirming other rulings).

Issue	Plaintiff's Argument (Boyd)	Defendant's Argument (State)	Held
Whether Boyd’s motion alleging the sentencing court relied on inaccurate information invoked the court’s jurisdiction to correct a sentence imposed in an illegal manner	Lopes’s taped statement, discovered after sentencing, shows lesser culpability; sentencing occurred under the erroneous belief no tape existed, violating Boyd’s right to be sentenced on accurate information	The claim attacks the plea/conviction (reduced culpability) not the sentencing procedure; even if considered, the sentence was an agreed fixed term Boyd accepted	The motion was a collateral attack on the plea and not a colorable claim to invoke postsentencing jurisdiction; trial court should have dismissed (not merely denied) that portion
Whether practical relief (a reduced term) could be granted via a motion to correct an illegal sentence	Boyd sought relief (less than 20 years) based on the new tape	State argued sentence resulted from an agreement; only vacating the plea could reduce the term	Court: relief would require opening/vacating the plea agreement, which a motion to correct an illegal sentence cannot accomplish; hence outside its limited jurisdiction

North Carolina v. Alford, 400 U.S. 25 (1970) (allows a defendant to plead guilty while maintaining innocence when evidence strongly points to guilt)
Brady v. Maryland, 373 U.S. 83 (1963) (prosecution’s suppression of material exculpatory evidence violates due process)
State v. Casiano, 282 Conn. 614 (2007) (post‑sentence motion to correct illegal sentence cannot be used to attack the validity of a guilty plea)
State v. Jason B., 176 Conn. App. 236 (2017) (defines a "colorable" claim necessary to invoke trial court jurisdiction under Practice Book § 43‑22)
State v. Evans, 329 Conn. 770 (2018) (clarifies that to be colorable a defendant need only show a possibility of prevailing)
State v. Cruz, 155 Conn. App. 644 (2015) (describes the restricted post‑sentencing jurisdiction to correct illegal sentences)